In a landmark ruling, the Supreme Court directs AIIMS to admit a medical aspirant with 68% locomotor disability under the Scheduled Castes PwBD quota for the MBBS UG course 2025. The Court emphasizes the right to reasonable accommodation as a fundamental right.
The Supreme Court of India has emphasized that providing reasonable accommodation to persons with disabilities is not an act of charity but a fundamental right. This right is rooted in the Constitution, specifically Articles 14, 16, and 21, which guarantee equality, non-discrimination, and the right to life and personal liberty.
The Court made this observation while directing the All India Institute of Medical Sciences (AIIMS) to grant admission to a medical aspirant with locomotor disability under the Scheduled Castes Persons with Benchmark Disabilities (PwBD) quota for the MBBS undergraduate course in 2025.
The Supreme Court also instructed the National Medical Commission (NMC) to revise its guidelines, keeping in mind earlier rulings by the Court, specifically in Om Rathod v. Director General of Health Sciences (2024) and Anmol v. Union of India & Ors. (2025).
This revision aims to ensure that no deserving candidate in the PwBD category is denied admission to the MBBS course, despite their entitlement.
The Court has given the NMC two months to complete this process before the commencement of counseling for the 2025-2026 academic session.
The Bench, consisting of Justice Vikram Nath and Justice Sandeep Mehta, made the following crucial statement:
“Reasonable accommodation is not a matter of charity but a fundamental right flowing from Articles 14, 16, and 21 of our Constitution.”
They further added,
“When administrative authorities create arbitrary barriers that exclude qualified PwBD candidates, they not only violate statutory provisions but also perpetuate the historical injustice and stigmatisation.”
The Court emphasized that the fundamental rights and dignity of PwD and PwBD candidates must be safeguarded by ensuring their assessment is individualised, evidence-based, and free from stereotypical assumptions that lack scientific support.
The appellant in this case, who has benchmark disabilities (PwBD), belongs to the Scheduled Castes category and aspired to pursue the MBBS course.
Despite his high merit, he was denied admission to the MBBS course under the Scheduled Castes PwBD quota. The appellant’s locomotor disability was classified as permanent.
After being denied admission, he filed a Writ Petition in the Delhi High Court, which was rejected. His appeal before the Division Bench of the High Court was also dismissed. This led the appellant to challenge the decision in the Supreme Court.
Upon reviewing the facts of the case and the assessment by a Medical Board, the Court noted that the appellant had successfully demonstrated essential skills such as chest compressions, intravenous cannulation, intubation, and suturing in a simulation laboratory.
The Medical Board’s report highlighted that the appellant used his existing digits effectively to perform these tasks.
The only minor issue the appellant faced was in wearing sterilized gloves.
In response to this, the Bench remarked,
“We feel that the mindset must change and this trivial aberration, by no stretch of imagination, can be a ground to deny admission to the appellant in the MBBS UG course, when he is otherwise qualified and scored exceeding high rank in the NEET-UG 2024.”
The appellant had secured an All-India Rank of 147946 in NEET-UG 2024. In the Scheduled Castes category, his rank was 7252, and in the PwBD category, it was 176.
The Court also noted that, in the first round of the NEET-UG 2024 provisional seat allotment, a candidate ranked 159816 had been granted admission to AIIMS New Delhi under the Scheduled Castes PwBD category. The appellant, with a much higher merit, had a rightful claim to the same seat.
Given these facts, the Bench held that,
the denial of admission to the appellant was “grossly illegal, arbitrary and violative of the appellant’s fundamental rights as guaranteed under Articles 14 and 16 of the Constitution of India.”
The Bench further observed that this action reflected “institutional bias and systemic discrimination” and undermined the constitutional principles of equal opportunity and non-discrimination.
The Court highlighted that the,
“constitutional mandate of substantive equality demands that person with disabilities (for short ‘PwD’) and PwBD be afforded reasonable accommodations rather than subjected to exclusionary practices based on unfounded presumptions about their capabilities.”
In light of these observations, the Supreme Court directed AIIMS to allocate a seat to the appellant for the MBBS UG course in 2025 under the Scheduled Castes PwBD quota.
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The Court made it clear that the appellant should be granted admission in the upcoming academic session, as he met all the qualifications and had demonstrated the necessary skills for the course.
This judgment reiterates the importance of upholding the rights of persons with disabilities, ensuring that they are not excluded or discriminated against due to arbitrary practices or baseless assumptions about their abilities.
It also serves as a reminder to educational institutions to provide reasonable accommodations and ensure equal opportunities for all students, irrespective of their disabilities.
Case Title:
Kabir Paharia vs NMC
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